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Sandbar Wholesale Trust managers took over and told the
former employees of Marvin L. & Barbara J. Barmes they
could be contracted by Sandbar Wholesale Trust and
would have to fill out new paperwork, which included;
Work for Hire Statement, U.S. Department of Justice
Immigration and Naturalization Service Form I-9,
Late/Absenteeism Policy, Affidavit of Citizenship and
Domicile, Access to Trade Secrets and Confidential
Information and Form W-8. * * * No Form W-4 filled out.
Upon the completion of the above paperwork they would
be Independent Contractors for Sandbar Wholesale Trust.
Enclosed you will find two letters. One from Gregory
Paul Karl, CPA to Internal Revenue Service. The other
from Internal Revenue Service, Chief Accounting Branch,
Charles F. Felthaus to Gregory P. Karl, CPA. Sandbar
Wholesale Trust is a Pure Trust. A Pure Trust organi-
zation has no tax requirements, therefore an Employer
Identification Number is not required. [Reproduced
literally.]
The two letters to which petitioners referred in the protest
affidavit were copies of the Karl letter and the Felthaus letter
that Sovereignty included in its promotional materials and
provided to petitioners.
Federal Employment Tax Returns
Federal Employment Tax Returns--Petitioners
On July 7, 1995, Ms. Barmes signed Form 941, Employer’s
Quarterly Federal Tax Return (Form 941), for the quarter ended
June 30, 1995, which was filed under the name “Marvin L. and
Barbara J. Barmes PTR”, EIN 35-1305131. That form reflected
total wages, tips, and other compensation paid by Marvin L. and
Barbara J. Barmes PTR in the amount of $304,990.23.
On October 5, 1995, Ms. Barmes signed Form 941 for the
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